Williams v. State, 2016 Ark. 459

Michael Lee Williams was convicted by a Pulaski County jury of five counts of aggravated robbery and five counts of theft by threat; sentenced to 50 years. The Arkansas Court of Appeals affirmed. Williams sought Rule 37 relief in circuit court alleging ineffective assistance of counsel.
Williams argued trial counsel was ineffective for failing to call three codefendants/witnesses (Antonio Bozeman, Joe Bell, Johnathan Hattison) who said Williams stayed in the car and did not participate in the robberies.
At the Rule 37 hearing, the three witnesses testified consistent with Williams’s claim — that Williams accompanied them to the scene but remained in the car.
Trial counsel testified his defense strategy was misidentification: he argued Williams was not present at the scene and emphasized differences (e.g., facial scars) witnesses failed to describe when identifying perpetrators.
Counsel chose not to call the three witnesses because their testimony that Williams was at the scene would have undermined the misidentification strategy by placing Williams at the scene during the offenses.
The circuit court denied Rule 37 relief; the Supreme Court of Arkansas affirmed, holding counsel’s decision was reasonable trial strategy and not deficient under Strickland.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether counsel was ineffective for not calling three codefendants/witnesses	Williams: counsel was deficient for failing to present exculpatory testimony that he did not participate in the robberies	State: counsel reasonably declined to call witnesses because their testimony would place Williams at the scene and undermine misidentification defense	Court held counsel’s omission was reasonable trial strategy and not deficient under Strickland; Rule 37 denial affirmed

Strickland v. Washington, 466 U.S. 668 (1984) (two-prong ineffective-assistance test: deficient performance and prejudice)
Sartin v. State, 400 S.W.3d 694 (Ark. 2012) (appellate standard: defer to circuit court unless clearly erroneous)
McDaniels v. State, 432 S.W.3d 644 (Ark. 2014) (deficiency prong requires showing counsel was not functioning as Sixth Amendment counsel)
Noel v. State, 26 S.W.3d 123 (Ark. 2000) (trial strategy deference; decision to call witnesses rests with counsel)
Howard v. State, 238 S.W.3d 24 (Ark. 2006) (matters of trial strategy are within counsel’s professional judgment)
Anderson v. State, 385 S.W.3d 783 (Ark. 2011) (no need to address both Strickland prongs if one is not shown)